Legal

MyFreud Privacy Policy

Effective date: 24 May 2026

This Privacy Policy (“Policy”) explains how MEDRIX LTD (Company No. 16211156) (“MyFreud”, “we”, “our”, or “us”) collects, uses, stores, discloses, and otherwise processes personal information when you use our services, including the MyFreud mobile application, website, AI-powered wellbeing features, journaling tools, CBT sessions, subscriptions, and other interactions with us. This Policy forms part of the MyFreud Terms of Use.

1. Who We Are

Data Controller:

Privacy contact: privacy@myfreud.com
Support: support@myfreud.com

2. Important Notice About Mental Wellbeing Information

MyFreud provides AI-assisted wellbeing tools, self-reflection tools, journaling, onboarding assessments, mood tracking, and CBT sessions. Information processed through MyFreud may relate to wellbeing, emotional state, mental wellbeing concerns, sleep patterns, energy levels, concentration, reflections, and journal content.

This information may qualify as special category personal data under UK GDPR.

We process such information only where permitted by law and implement reasonable technical and organisational safeguards to protect it.

MyFreud is not a medical device, does not provide healthcare services, and is not intended to diagnose or treat medical or psychiatric conditions.

3. Personal Information We Collect

We may collect information:

• directly from You;
• automatically through use of the Service;
• from authorised third parties.

3.1 Information You Provide

Account Information may include:

• Name
• Email address
• Sign-in credentials
• Age or date of birth
• Gender
• Country or region
• Profile settings

Wellbeing and Onboarding Information may include:

• Selected concern
• Severity responses
• Sleep responses
• Wake-up habits
• Energy responses
• Concentration responses
• Voice preferences
• Goals
• Progress responses

Journal and Session Information may include:

• Journal entries
• Mood logs
• Voice inputs
• Reflections
• Responses during CBT sessions
• Conversation history
• Personal insights

Communications may include:

• Emails
• Support requests
• Feedback
• Survey responses

Subscription Information. Purchases are processed through platforms such as the Apple App Store and Google Play Store. We may receive subscription status information but do not directly receive payment card information.

4. Information Collected Automatically

Device Information

• Device model
• Operating system
• App version
• Browser information
• Device identifiers

Usage Information

• Session duration
• Screens visited
• Feature usage
• Crash logs
• Engagement metrics
• Performance information

Technical Information

• IP address
• Approximate location
• Diagnostics
• Error logs

5. Information From Third Parties

We may receive information from:

• Apple Sign In
• Google Sign In
• App stores
• Analytics providers
• Cloud hosting providers
• Security providers
• Customer support providers
• Attribution providers

6. Cookies and Similar Technologies

Our website and services may use:

• Cookies
• SDKs
• Analytics tools
• Local storage
• Similar technologies

We use these to:

• operate the Service;
• improve performance;
• maintain security;
• analyse usage;
• remember preferences.

You may manage these through browser and device settings.

7. How We Use Personal Information

Provide Services

• operate accounts;
• deliver AI features;
• provide journaling;
• personalise onboarding;
• personalise CBT sessions.

Improve Services

• improve app performance;
• test features;
• understand engagement.

Communicate

• provide support;
• send service notifications;
• respond to requests.

Subscription Management

• verify subscriptions;
• manage entitlement access.

Security

• detect abuse;
• prevent fraud;
• investigate misuse.

Legal Compliance

• comply with legal obligations;
• enforce policies;
• respond to lawful requests.

Business Operations

• accounting;
• auditing;
• business administration.

8. AI Processing

MyFreud may use AI systems to:

• generate responses;
• personalise wellbeing content;
• personalise CBT sessions;
• summarise inputs;
• provide conversational features.

AI-generated responses may:

• be incomplete;
• contain inaccuracies;
• be unsuitable for Your circumstances.

You remain responsible for decisions made using outputs.

MyFreud should not be used as emergency, medical, psychiatric, or therapeutic advice.

9. AI Training Statement

MyFreud does not sell users’ sensitive mental wellbeing information.

Personally identifiable:

• journal entries;
• onboarding responses;
• conversations;
• wellbeing responses;

are not used to train public AI models unless explicit consent is obtained.

10. Legal Bases Under UK GDPR

Where applicable, we process personal information using:

Contract — to provide the Service.

Consent — for:

• sensitive wellbeing information;
• optional features;
• marketing where required.

Legitimate Interests — to:

• improve the Service;
• maintain security;
• analyse performance.

Legal Obligations — to comply with laws.

11. How We Share Information

Service Providers, including:

• cloud hosting;
• infrastructure;
• analytics;
• AI providers;
• support providers.

App Stores, including Apple and Google.

Legal Authorities, where required by law.

Corporate Transactions — during mergers, acquisitions, restructuring, or financing.

With Your Consent — when You authorise sharing.

12. International Transfers

Your information may be transferred outside the United Kingdom.

Where required, we implement safeguards including:

• contractual protections;
• access controls;
• organisational safeguards.

13. Data Security

We maintain reasonable technical, organisational, and administrative safeguards designed to protect information. No system guarantees complete security.

14. Data Retention

We retain information only for as long as necessary to:

• provide the Service;
• comply with legal obligations;
• resolve disputes;
• maintain records.

De-identified information may be retained longer.

15. Your Rights

Subject to applicable law, You may request:

• Access
• Correction
• Deletion
• Restriction
• Objection
• Portability
• Withdrawal of consent
• Complaint review

Requests: privacy@myfreud.com

16. Marketing Preferences

You may:

• unsubscribe from emails;
• disable notifications;
• modify communication settings.

17. Children and Young People

MyFreud is not intended for children under 13 years old.

Users aged 13–17 should only use MyFreud with parental or guardian involvement where required by applicable law.

18. Complaints

If You believe Your data rights have been infringed, You may contact privacy@myfreud.com. You may also contact the UK Information Commissioner’s Office (ICO).

19. Changes to This Policy

We may update this Policy. Material changes may be communicated through:

• app notifications;
• website notices;
• email.

Continued use after updates means acceptance of the revised Policy.

20. Contact Us

Privacy: privacy@myfreud.com
Support: support@myfreud.com